Document 6b0LJR9Qwdm9MN83298jZqG3R

ROUGH. ORATI - 1 1 /1 ^ ^ . onniHS " ^ r . '^Introduction " "Problem reness IT. Nature or ite Prebles Hoos&r oh1ond-medioal -inpu t T. S ffe e t cn Monsanto 71. S f f e c t on Castane? T U . In v oivesent u l t i otther pr odacers 3TTT. .Souroes of Contagi n a tic a 22. R ecent te c h n ic a l changes v t l c t bave b e a rin g on tiie contam ination I . Courses of Action Heccmnended Course of Actios Im p le a e sta filo s of th e Ree a m ended Course o f A ctios A Xsamdiahe Actios { } 3 I s t e r i a 1-3 acnths C. Short term - .3-5 aosths B. Long te sa (1-3 yeara) 1. 1Research nedlcal - 5.. Patent. ;2* ;:: M anufacturing 5 . g a tiro a amrfcal Costata i - '* 3*. Engineering; ; Marieet /. 7 . Legal rv 7 '' /^ 7 , 8. Publie Relations 9 Oth Y* ! f !I \ PCS SHmOOOiTAI PQESJTXCH ABATSGNT PUH Introduction Cn 15 October the *A3 IOC" C oaaittee consisting of Messrs. M. F a rra r, ?. lodges, S. John, V. Hishard, and 5. Wheeler issued a re p o rt surmarisin g the polychlorinated biphenyl (PCS) p o llu tio n probless fre a the Icnown a v a ila b le information to d a te . Out of th is re p o rt ease considerable in farsatio n , conclusions, and recoasendations which we have atteapted to t i e to g eth er into a plan of action in th is document. Our o b jectiv e has been to take a reasonable and responsible approach to the e n tire problem. Before we get into the 'problem, we should c la r if y the meaning of PCS, the nature of the e n tire lin e , and how these t i e in to our product lin e c i Aroclors -r - - Monsanto entered the Arcelor market in 1930 by acquiring Swain L sg t^ ca l caggaagp <s? today *& ea r A; ^*4? m'\'<Aq^ ^ T I \ "' v' f. S2 iiii a*C.**^ mu Uwri.yu'-- jtasr Arcelor 2254 -- *'el > vent oat o f Amiston, Alabama to GS' in 1931s ^Since th a t tla e the r k e t has grown to 170 t o `2OCK4worldwide* " Chemical Biphenyl Monsanto Product Line Hatero of M aterial a t Ambient Solid Monoehlorcbiphenyl C ( J (i DlChtra^!^ ,,,,*\l TZ r iOcalorOo c l ph"enyl-.- diOpCOCi!Quaterchlsrobiphenyl Pentachlorcblphenyl 9 a rHeptaehlorcbiphenyl F*1 ff \ * / V<f ( IDeeanSQorcBTstuBnTl * ^T^Vs-^f^v- Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 2243 Aroclor 2254> Aroclor 2250 ' Aroclor 1262 w Aroclor 1263 Aroclor 22725 . thin liquid (oil) thin flu sh water. oily type fluid m aterial Thicker - transmission ell Heavy-Mclas3es Thick - ta r Very th ic k - liq u io Solid re c a s t to the eco logical 373tea by contamination from polychlorinated biphenyl (PCS). Stctessiveness The problem involves the en tire United States Canada and sections c f Sarope e sp e c ia lly the United Kingdom and Sweden. As the in v e stig a tio n broadens other areas of Sarope, Asia and Latin America w ill surely become involved. Svidenee of contami,nation have been shows L i some o r the very remote p a rts 0f the world. The involvement could and most lik e ly w ill follow th e LOT in v e stig a tio n s. IT, w Hature of the Problem Professors Wida a rk and Jensen of the I n s t i t u te of A nalytical Chemistry a t Stockholm, Sweden in November 1965 -a nnounced and confirmed f in d ir; PCS i s f i s h , birds and eggs. Subsequent findings were made in 1957 1: Great B rita in . In February 1959 P ro fesso r Hisebrough of the u n iv e rsi' o f C alifo rn ia published as a r tic le i s th e San Francisco Chronicle relaying- h is findings of PCS in th e e s v irc sse st of the United S ta te s . Monsanto confirmed th e presence of ?C3 `s in old-1969 and confirmed th e adequacy o f work by Vidmaxk and Jensen and others; truly the PCS's a re a worldwide, ecolo lo g ical problem.- c - n- A nalysis indicates the eavircnnentaX presence of the 5 md> ^ n h la r is a te d .biphenyls which. take the fcppa^SRaee `Pf- A r a le r 123b i.* A rcelor 1260. ' We hare strong in d icatio n s th a t Aroclor 12% or at le a s . p a r t of i-t degrades biologically. Since the Aroclor 12% contains arc; 7* percent of the 5 chlorine biphenyl o r higher we cannot ro le out th e p o s s ib ility th at the observations nay be a concentration affect of the h ig h er chlorinated biphenyls of Aroclor 12%. To date there have been no reports of finding Aroclor 12% present in th e environnent (except outside the e fflu e n t of our plants where we 5cr Arcelor 12% is present). The seriousness of the problea can b e s t be spelled out as follows: 1 . Fish - Marine or aquatic species concentrate ?C3 in the f a tty * tis s u e . Tonic is sn ail q u an tities (down to 5 ppi) to sen sitiv e sa l i f e such as shriap. 2 . B irds - Predatory species feeding on the marine or aquatic lif e ca fu rth e r concentrate PCS to possible harmful e ffe c ts . S p ecifica lly in birds PCS can a ffe c t the caleims metabolism leading to egg she! im perfections which prevents proper hatch of' the young. In f a c t , Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCS's in co n tro lled te s ts . 3 . Man -'T here is no harmful effect loown to man or other mammals af* 40 years of production. In v estig atio n s a re underway by various sources. STR Q2W3 h . P o litic a l and Public Bmotion - ?C3*s are fa ls e ly t^w*** with BET because PCS's show up in the a n a ly sis fo r EOT. PCS's are linked * o th e r permanent type chlorinated hydrocarbon p esticid es. This . becomes p a rtic u la rly serious sin ce about every a r tic le , of. food i n country is being examined fo r a tr a c e of these m aterials. flktti 'VL./>~\ S d. /'S's* --;1i-----c-*w-*i-*--*i 'r v * !> SsI. a. *r. iv W $ ?8t , I>Eft?|Cfp|Sp Mr IH Rn<*riijV **t..i* .V' ' ^ i ' ' > H eptachlor * i " % fi liindano 7 i' (lethoyychlor f-v -K . %\ l o,p DPT y PP.* bon PP* DpD 5 Mdrift y Dleldrtn *3 5.#f3 ' i Mr 5 .'Ci .i ii i! -V ;r {* a t ift . o_ V. E ffe c t on Monsanto a t states on % s3.dwi.de "-basis; . . - V > : '.`l ... ' / sa '*ste' W*'- :1fSiMMi.-.y V '"*J' `V * ' `" .U.w ^ Total/?ear 34? I ts . 104? lbs. $5? v $2-3? S.P. $2231 $3-11? 0 .?. Already competition is using certain data against us In competitive situ a tio n s. A. Legal l i a b i l i t y D irect law suits are possible. The m aterials are already present in nature having done th e ir "alleged damage". A ll customers using the: products have not b e o ffic ia lly n o tifie d about known effects nor cur labels carry th is information. These are only a few of the * po ssib le leg al im plications which would best be covered by the leg al department. B. Public Image The corporate image of Monsanto as a responsible member of the business world genuinely concerned w ith the welfare of our environ ment w ill be adversely affected w ith Increased p u b lic ity . The evidence proving the persistence of these compounds and t h e i r u n iv ersal presence as residues i s th e environment i s beyond questioning. This combined with c e rta in scare publications is c e rt to give an adverse image. G uilty^association (with SET) w ill p re v a il as the backgro und while actual fa e ts may be sparse. C. Customer Helatlons STr 02l,* * Some customers who presently use th ese m aterials w ill be "seared of to other com petitive products. Products associated with the same name or "trademark"' w ill be adversely affected i e . , TherminoliT' sm Pydraal and Aroclor. Competitors w ill use the information fo r-an i n f luence on Monsanto products. Custom ers m i l seek other "outs* r a th e r than become involved. V I. E ffect on Customers -and Ultimate C ortuatrs . CBe of the unique* fe a tu re s of ?C3's i s t h e i r f i r e resistance. Here th e basic decision whether to risk liv es due to f i r e or risk extinction o f, some species of b ird s. In this ease the ?G3 would probably be accepted as a necessary p o llu ta n t and to le ra te d under c o n tro ller conditions. A. .. Z le c tric a l Industry - Capacitors and Transformers use Arocior because i t is the best inexpensive d ie le c tric flu id available. B. Pood Processing - Bulk "deep frying" u n its fo r potato chips, f is h , and doughnuts use the fire re sistan c e flu id as an in d irect heating medium C. Die C aster -- and o th er hot m etal working in d u stries f ir e re sista n o flu id s to p rotect th e worker? A ffects a wide range of p la stie s and adhesives because the ?C3 serves as'the p lasticiser. ....A wide--range-of p a in ts and coatings a re affected. The "Carbonless" carbon paper used so widely would disappear. 7 E . Involvement With Other Producers Although Monsanto i s most probably responsible fo r the D.S. c c n ta sln a t: asd J o in tly responsible with MCL fo r .the limited Kingdom problem, we cannot accept re sp o n sib ility for the w orld. There are five known producers in the free world, several possible producers behind the ire : cu rta in asd eouple of additional companies making overtures about entering th e business. Monsanto re p re se n ta tiv e s have on one occasion discussed -this, problem, with a eouple of these producers but. they expressed no great concern. In fa s t, i t Is highly possible th a t one c these manufacturers i s dumping his waste in to the Rhine River, Certa an? asbiom taken by one prsdaser I I I most assuredly affect the other v$i plan o f actios could be evelope b a t w ill Best probably have to be spearheaded by Monsanto.- I t is a ls -lik e ly th a t producers of other chlorinated products used with ?C3 's w ill be dragged in to th e Investigation. * Sources of Contamination Although there nay be some s o il and a i r contamination involved, by fa: the most c r itic a l problem at present is w ater contamination. To our knowledge to date the contamination can be broken down into two geners .categ o ries, open and in d irect p o llu tio n . A. Open Pollution - Cur manufacturing f a c i l i t i e s sewered a sise a b le q u an tity ef ?C3 's in a years tim e. 1 . Fluids Fluids are probably the aost open source of pollution because th e ir m obility. They also may be th e le a st serious because th a re generally the lower ch lo rin ated m aterials. 2. Slectrical S le c tric a l customers have in the p a s t sewered th e ir wastes. 3* Heat Transfer Seat tra n sfe r customers have sewered th e ir objectionable and th e ir spilled material. 4. .industrial These flu id s have generally been sprayed in to drains, washed m down sewers and generally regarded as very harmless. A ll o f th e fluids have had the *|sk* c o n stitu e n t dumped as d i r t reads dedusting agent* which inadvertently found i t s way back tojttxe stream . r these manufacturers i s dumping his waste in to the Shine Hiver. Certain f aay actio n tik ta by on* pngse? w ill r e s t assuredly afreet. the other. 1& in s t t r y po ssible z' jo is t plan/ of' action could be developed ' ' but w ill most probably have to be spearheaded by Monsanto.- I t is a lso TlU-itieely th a t producers of other chlorinated products used with ?CB's w ill be dragged in to th e investigation. * ttt. Sources of Contaaisaticn Although there may be seme so il and a i r contamination involved, by f a r the most c r itic a l problem at present is w ater contamination. To our knowledge to date the contamination can be broken down into two general .ca te g cries, open and in d irect p o llu tio n . A. Open Pollution - Cur manufacturing f a c i l i t i e s sewered a sizeab le q u an tity of PCS's in a years tim e. r 1 . Fluids l Fluids are probably the most open source of p o llu tio n because o th e ir m obility. They also say be th e le a st serious because the a re generally the lower ch lo rin ated m aterials. 2. Sleccrical 31ec epical customers have In th e p a s t sewered th e ir wastes. 3. Seat Transfer Heat tran sfer customers have sewered th e ir objectionable and th e ir spilled material. 4. -Industrial These flu id s have generally been sprayed in to drains, washed i f down sewers and generally regar ded as very harmless. A ll of th e fluids have had the "|Win5k-? c o n stitu e n t dumped on d i r t roads - i a "dedusting agent" which inadvertently found i t s way back to the stream . i i c 5. Plastics c.8 - have not found and eanncft fin d t h e i r 37 back to streams in e pollution. 5 In d irect Shipping containers and the cleaning, thereof fo r subsequent use a source cf contamination^ 1 . Fluids a . E le c tr ic a l - Disposal of "burned out" transform er and cap acitors may find i t s nay back to s tre ss . Scrap u n its (new) are generally disposed of in land f i l l s but could possibly get back to the s tr e s s . b . Seat T ransfer - Leaks could contaminate. c . I n d u s tr ia l - Cross produc t c o n tasira tio n ca rried cut of a a ir compressor. Residual m aterial carried os p arts 2. Plasticisers a . Process Contamination from Washing (1 .) Environment Contamination Swimming pool paints Incineration of wax .coatings T raffic paints (2 .) Product Contamination STR 021*?4<9 Coating for tank lining Certain adhesives Recent Technical Changes Which Have Bearing on the Contamination A* F lu id s The sources of pollu tio n were pointed out as they bare been in tr p a s t because we a re dealing with th a t ouantitv a f m aterial in oh r 9- environnent today which was deposited over the past fo rty years, Ke .c o rre c tiv e action to reduce contamination in the la s t two years. There -.-h a v e also been te c h n ic a l advances which have brought about the use of lower chlorinated biphenyls which may. be ,,an advantage because to date low chlorinated ones have sot bees id e n tifie d present in nature. 1 . E le c tric a l - 2 ce larg e customers have established collect systems th e waste is recovered. Incinerators are being investigated and b u ilt fo r the d isp o sal of the m a te ria ls. There has been a s h if t away from the higher chlorinated types products and could probably shift almost e n tir e ly away from those products. 2. Heat Transfer - System have been tig h ten ed up and redesigned oc .confine the contents Here^to^* th e tren d has been to s h ift away from the higher chlorinated m aterials. 3* In d u s tria l - S e llin g ponds have been b u ilt by the large marufactur to catch the m a te ria l and decant o ff the PCS fo r reprocessing, tren d here as the other fluid areas has been towards the lower chlorinated m aterials. P lants - The p la n ts effluent has been passed through limestone vr~ provides surface to catch seme of the m aterial. 3u t high concen tra tio n s can be found in cur e fflu e n t (th a t i s re la tiv e to th ese findings In nature causing the problem). 9 B. P lasticiser Quite apposite to flu id s the trend in p la s tic is e r Arcelor has been to hig her chlorinated biphenyls. In p la s tie ls e r s the lower chlorinated, biphenyl w ill not be a s acceptable so lu tio n however the lower c h lo ri terphenyl-c-coold o ffe r a possible sc 10 Courses of Action A' ,a ... .-w iv . .................................. "e esisw t &asy"the findings "and the ac q u isitio n s by the various __ agencies. IT we tooic no action we would- lik e ly face numerous s u i t s . "7 We w ou ld 'let government tolerances be based on public and p o litical pressure along with ary experimental or developed data which they may generate. We would Boat lik e ly be forced out cf th is business. Other product areas would be adversely affeoted-r We would project an image as an Irre sp o n sib le member of the business world. Project poor customer re la tio n s . The only advantage to t h is technique offers i s i t reduces the co st but th is too must be weighed against p o te n tia l loss of business. 3 . Discontinue Manufacture of All Polychlorinated 3iphenyls (PCS) Although we a l l r e a lis e this could be an eventually unfortunately th e so lu tio n is n et th is simple' Assuming we did step manufacture Immediately the pollutants are present in the environment, the l i a b i l i t y is present and possibly by the s h iftin g to the lower chlo rin ated m aterials and the recovery techniques the contamination may already be reduced to an acceptable le v e l. Obviously the e n tire business would be lo s t without any o r very few su b stitu tes to be o ffered . Other produet areas would be affected . F inancial loss could be considered due to raw M aterial contracts, customer c c n tra c and ro y a lty -- secrecy contracts. Competition would take advantage oa a l l fro n ts. We would be adm itting g u i l t by our ac tio n s. Loss of c a p ito l investment i s the plant* associated u t i l i t i e s , and asso c ia te d processes. We would possibly gain a l i t t l e publie image on this action. ST 021951 C. Bespcnd responsibly, admitting th a t th e re is growing evidence of environmental- contamination by the h ig h er chlorinated biphenyls- and take action as new data is generated to correct the nroblea. - 11 Vi-- Shis approach cold enable os to phase out the higher chlorinated. _______ 'a__fa_aa;a,r2t.a?*,'*BSar are no r-he&sssar: o r r e a lly desired* Veeoold narinri.se th e corporate- Image by p u b lic isin g th is a c t. Ve would reduce a known p o llu ta n t. 'A dditionally we could gain precious tim e needed to develop new products and Investigate further the- lower chlorinated m aterials. As new research d a ta I s generated our course may be a lte re d If considerably. C ertain H alted a e tlc o s may reduce or lim it the problem. ( {li Carsa cf Action Sascd, s z in ib r2.iriaa a * iliil Uxia> th e' only recsmaendaticn we can. honestly sake la respond responsibly adm itting th a t there Is growing evidence of environmental contamination by the higher chlorinated biphenyls and take actio n as sew data i s generated to correct the problem. Implementation of the Recommended Coarse of Action A. Immediate (ay 12-1-69} ' 1 . Set up a task force under a p ro je c t manager or the equivalent .responsible for in itia tin g , d ire c tin g and implementing a l l a c tio : th a t Monsanto decides ts take. This Includes su ffic ie n t budget necessary to eope with the Immediate problems. This ta sk fo rc e should include representatives from Medical, Legal, Research and the two involved Marketing Croups and ?ublls Relations and mast conduct lia is o n with MCL and other locations Involved in th e problem. 2. Decide- on timing and content of any public and/or customer n c t l f cation of ?C3 problem. B. Interim (Within 3 months) Fluids Plasticisers 1 . Confirm Aroclor 125^/Aroclor 1 . Announce d iffe re n tia l b etu ee r 1260 re found In the envi fluids/plastlciser uses. ronment . 2. P ublicise the d if f ic u lt an al, 2 . Announce safety of other PCS' tasks. chlorinated terphenyl. . 3. P rotect other ?C3/chl. terph. 3- Educate customers on. c o n tro l effluent for a ll products. Announce plans to reformulate c e rta in Thexslnols and Pydraul 4. where control of the product I n itia te program to develop- A 225*1 <fc 1260 su b stitu te s la difficult. 5. Emphasise b e tte r central over 5. Investigate with marufaocur?. .. t f e s ^ ? r ..1254^& HiC .. . ... ..,,,, .fthei feaslbiIi^-sQg-ya4^.?^-3:^ 1;;: * t6 6 B titla te ' easterner education or S-. Analyse 12tg seed fo r effluent control of a l l produets. 7 . D eterm ine e e a p e sitlo s of a l l PCS`3. Develop a esaprehenslve Program Short Tern (within th e nest 12 months) 1. . Research - Sxpand program fo r more meaningful biodegradation Medical studies and confirming a n a ly tical re s u lts . Expand -tonicity studies, Follow developments concerning p u b lic ity and those developments covering p o l i t i c a l im plications of PC3 contamination. 2 . Marketing - Discontinue or su b stitu te replacement products f a r those ap p lications of iro e lo rs 3254 and 1250 where the A roclor r emains mobile. Work with easterners to clean up plants on other Aroclors. Report the h a b itu a l v io lato rs o r "do nothings" to the product group. Reclaim or safely dispose of fluids.* Consider renaming products th a t do not contain PCS, Follow arc 'r e p o r t market developments such as customer disposal systems. Fellow and rep o rt any p o l i ti c a l or public feedback which, cay a f f e c t th e contamination problems and must be coordinated .with Medical, Research and Legal.* 3* Production - Clean up plants and stop gross contamination. 4 . Legal - Define our-present p o sitio n , recommend reasonable a o t l th a t w ill not usduely alarm th e market but reduce the excecurc In terms of l i a b i li t y . Coordinate reeasmendatian* ,'viiSh barite c * Certainly discussions should be held with other producers with: same period to detersive t h e i r planned course of a c tio n , i f an; 'Long Range Tentative CutUse (Proa 1 Tear to 3 years) R ealizing th a t the comprehensive pr ogram oust be outlined the "Lcn^ Range Tentative C atllne" is meant to serve as a guide: A ll aspects of th is program should review q u a rte rly by Organic Management. 1. Research-Medical Continue biodegradation stu d ies and an a ly tical support Isomer d istrib u tio n Toni cl t7 and metabolism studies Water soluble removal Incineration analytical support Confirmation analy tical - Contract academic research f o r reference Develop new and improved forma la tio a a 2. Manufacturing a . Process Research and Development (1.) Id en tificatio n of ty p ic a l Aroclor Isomers (2,) Develop control fo r e fflu e n t composition * (2-) Test substitute formulations e tc . (b.) Develop new processes b . Clean Dp Plants e . Modify processes to meet market heeds 3* Engineering a . Develop and s e t up an p la n t locations in cin eratio n systems b . Design sew processing equi pment as necessary b . Marketing-'" a. Specify alternates or changes b . Customer- lia is o n r 15 - , * 3t ra c is ia or discossil a i flu id s ou QT3C os nftmr association problems 5 Patent Investigate trademarks registered,:. Cover e lth patents any worie f e l t paten tab le 6. Snvironmental Control . Develop cheap disposal systems fo r customers a. Incineration or pyrolysis b. "Biodegradation unit etc. * c. Consultants In pollution control 7 . "Legal In v estig ate and define cur p o sitio n , on Royalty secrecy agreements. Contracts - Bear M aterial end Customer 8. Public Relations Portray to public positive actions a t correcting the contamination problem. Belease p erio d ical statem ents covering our position. P robability of Success 2X7. Cast of Program 3" coats haunt b&sa elasrJ.y 4Wf!sJL a t 't h i s 't : However, at east estim ate of 220,000 f o r tosleologieaX work alone has been presented. Tentative figures Indicated under the worst conditio: the e n tire program could run as high as 2 .0 -2 .5?L At th is stage i t : very d iffic u lt I f not Isposslble to develop a reasonable east fig u re i one p o in t Is elear I t w ill be larg e r than the normal research budget : handle. Per th is reason, assuming the approach Is acceptable, we sha: be forced to ask fo r additional appropriations to fund the program. X7. Future Follow developments on the problem as they unfold. Develop an aggressive research pr ogram to confirm or deny findings an: b e tte r understand the problem. Develop easts fo r th e duplementatlon o f the Recommended course of action. Develop sp ecific actio n s with each department Involved Submit the actions w ith costs fo r approval Develop _ tim etable to solve the o v e ra ll problem. Prepare fo r "preelpltlous pullout* or d ra stic leg isla tiv e action. a lth we do not fe e l th is I s a lik ely p o s s ib ility . I i >CTXGH^_ DO NCrHISg DOLLARS G cpit and m urciar? 73, ^ ..... . * > . r 73 PROFITS * ' i vv -. 'i -,'i- FHCBABXIOT OP SUCCESS V*:7, "';.0' ----r 70 TX 72 73 7^ f Aus UA&UTKf R r , k* / i f-- p H o /i r W r >Fs o ce